AC 120-16E

Historical

Advisory circular · Air Carrier Maintenance Programs

A newer version is currentThis is a historical version. AC 120-16G is the version in force, approved January 4, 2016.
Approved
September 11, 2008
Last reviewed
August 6, 2024
Cancels
AC120-16D
Cancelled by
AC120-16E CHG 1
Family
AC 120-16 · 6 versions
Revision
E
14 CFR parts
119, 121, 135, 1, 91, 43

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed November 22, 2025.

Show pages 1–6

Par 105 Page 3 (and 4)

(3) Competent personnel with adequate facilities and equipment perform maintenance and alterations on your aircraft.

b. You should also have a system of continuing cycles of surveillance, investigation, data collection, analysis, corrective action, and corrective action verification that ensures all parts of your maintenance program are effective and are being performed in accordance with your manual. Effective means that the desired results are being achieved according to the maintenance program objectives and the standards that you, the air carrier, set.

106. AIR CARRIER MAINTENANCE PROGRAM ELEMENTS. An air carrier maintenance program includes the following 10 elements. This AC explains each of these elements individually. In some cases, there is another AC that provides more detailed information about one or more of the maintenance program elements. Where such ACs exist, this AC does not explain that element in depth.

• Airworthiness responsibility,

• Air carrier maintenance manual,

• Air carrier maintenance organization,

• Accomplishment and approval of maintenance and alterations,

• Maintenance schedule,

• Required Inspection Items (RII),

• Maintenance recordkeeping system,

• Contract maintenance,

• Personnel training, and

• Continuing Analysis and Surveillance System (CASS).

Par 200 Page 5 CHAPTER 2. AIRWORTHINESS RESPONSIBILITY

200. RESPONSIBILITY FOR AIRCRAFT MAINTENANCE.

a. Consistent with §§ 121.363 and 135.413, you, as a part 119 certificate holder, are primarily responsible for (1) the airworthiness of your aircraft, and (2) the performance of all of the maintenance on your aircraft.. Your air carrier certificate makes you a maintenance entity.

Under your air carrier certificate, you accomplish maintenance, preventive maintenance, or alterations, or you can use other persons who are not direct employees to accomplish that work.

Consistent with the FAA’s regulations at §§ 121.1(b) and 135.1(a)(2), the part 121 or 135 regulations govern each person that is employed or used by you for any maintenance, preventive maintenance, or alteration of your aircraft. Each of these persons who are used by you must be under your direction and control and must follow your maintenance program. You should note the definition of “person” in 14 CFR § 1.1

b. For any work done on your aircraft, you retain direct and primary responsibility for performing and approving all maintenance and alterations, whether that work is accomplished by you or by someone else (for example, a maintenance provider, such as a repair station).

However, you retain primary responsibility for the performance and approval of the maintenance done by that maintenance provider.

201. THE DIFFERENCES BETWEEN AIR CARRIER MAINTENANCE PROGRAMS AND PART 91 GENERAL AVIATION INSPECTION PROGRAMS. The following table provides a comparison of the differences between air carrier maintenance programs and part 91 general aviation inspection programs.

Element Part 121 and 135 Air Carriers Part 91 Owners/Operators Use of a maintenance or an inspection program.

Required to use a maintenance program for its aircraft.

Required to use an inspection program.

Responsible for the performance of maintenance in accordance with its maintenance program and manual, as well as the airworthiness of its aircraft, including airframes, aircraft engines, propellers, appliances, and parts thereof.

Responsible for maintaining the aircraft in an airworthy condition (§ 91.403).

Responsibilities within the relevant program.

NOTE: The wording in part 91 is deliberately different from the wording in parts 121 and 135 and is consistent with the difference between air carriers and other air commerce described in 49 U.S.C. § 44701.

Responsible for the development and use of the maintenance program and manual, determining the method of performing maintenance, a required inspection list, a continuous analysis and surveillance system, a Responsible for the selection of an existing inspection program and the scheduling of aircraft for the inspections, and; ensuring discrepancies that occur between scheduled inspections are repaired.

Page 6 Par 201 maintenance organization that can exercise operational control over maintenance operations, and other items that collectively and systematically serve to ensure each aircraft has been properly maintained for operations in air transportation and is airworthy.

Must determine what maintenance is required, how to do it, when to do it, perform that maintenance, and approve its own aircraft for return to service. May authorize another person to accomplish the maintenance work, but the maintenance must be carried out according to the air carrier’s maintenance program and manual.

The air carrier still retains the responsibility for the proper completion of maintenance (§ 121.363 or § 135.413).

Must make the airplane available to authorized and certificated person(s) who accomplish inspections and other maintenance.

Along with FAA oversight, is the primary authority with regard to its maintenance program. Holds the primary responsibility for the performance of maintenance in accordance with its maintenance program and manual, as well as the airworthiness of its aircraft, including airframes, aircraft engines, propellers, appliances, and parts thereof.

The authorized and certificated person(s) has the responsibility to perform the maintenance properly in accordance with the manufacturer’s manual and to approve the aircraft for return to service. The owner/operator does not have this responsibility. However, the owner/operator is responsible for ensuring maintenance personnel make appropriate entries in the aircraft maintenance records indicating the aircraft has been approved for return to service.

Par 300 Page 7 CHAPTER 3. AIR CARRIER MAINTENANCE MANUAL

300. AIR CARRIER MAINTENANCE MANUAL REQUIREMENT.

a. The FAA regulations (14 CFR §§ 121.133, 121.369, 135.21, and 135.427) require you to have a maintenance manual. It is a required part of your air carrier manual system. Some air carriers call their manuals “specifications.”

b. Your maintenance manual must be easy to revise, and have procedures for keeping all parts of your manual up to date. Your manual may be electronic.

c. You must make copies of your manual or appropriate portions of it (and changes or additions) available to those persons who are required to comply with it. You must also provide a copy to the representatives of the Administrator assigned to you. Each person who is furnished a manual, or appropriate parts, must keep it up to date.

d. Other regulations that relate to manual requirements are §§ 43.13(c), 121.135, 121.137,

135.23, and 135.427.

301. ROLE OF THE AIR CARRIER MAINTENANCE MANUAL.

a. Your maintenance manual is your key to standardized, consistent accomplishment and administration of your maintenance program.

b. Your maintenance manual:

(1) Identifies, describes, and defines your maintenance program.

(2) Provides instructions and procedures to administer, use, manage, and amend your program.

c. Your maintenance manual is a company publication, and you have sole responsibility for its organization and content, however, others may compile and publish it for you. Your maintenance manual may be electronic.

302. MAJOR SECTIONS OF THE TYPICAL AIR CARRIER MAINTENANCE MANUAL.

a. Organization of Your Maintenance Manual. Your maintenance manual should have a practical organization. Typically, it will have at least three sections: one covering administrative policies and procedures; a second covering detailed instructions for the administration, management, and accomplishment of the elements of the maintenance program;

and a third covering technical data that describes maintenance standards, methods, techniques, and procedures.

(1) Administrative Policies and Procedures. It is a management and administrative tool for organizing, directing, amending, and controlling your maintenance program.

Organizational charts delineating the functions, relationships, and lines of authority between

Page 8 Par 302 organizational elements and personnel usually are identified here. This part is where you list position descriptions, duties, responsibilities, and specific authority and responsibility attributes for each position within your maintenance organization. The authority and responsibility attributes should show who has overall authority and/or responsibility and who has direct authority and/or responsibility.

(2) Instructions for the Administration, Management, and Accomplishment of the Maintenance Program.

(a) This section contains detailed instructions for your management of the various functions and interrelationships of each maintenance program element, such as maintenance time limitations, recordkeeping, maintenance program management and oversight, contract maintenance management and oversight, and personnel training. This section usually includes a description of scheduled maintenance tasks, procedural information, and detailed instructions (or specific air carrier maintenance manual references) for accomplishing maintenance tasks.

Additionally, you should describe criteria for initiating functional evaluation flights in this part of the maintenance manual, along with procedural requirements for them. In this portion of your manual, you should also include criteria and procedural information for unscheduled inspections, such as those associated with lightning strikes, tail strikes, engine temperature exceedance, hazardous material spills, hard or overweight landings, and any very high load event.

(b) You should have a comprehensive process in the unscheduled maintenance portion of your manual that addresses those rare, extremely high-load events that occur to aircraft. Specifically, you should have inspection processes that are used following certain high load events. These particular high load events are those for which the subsequent inspection process might benefit from the use of flight data. Listed below are the events deemed most significant:

1. Flight Events

• A severe turbulence encounter,

• Extreme maneuvers,

• Exceedance of speed limitations, and

• Heavy stall buffet.

2. Ground Events

• Hard landings,

• Over-weight landings, and

• Drift landings resulting in excessive side/drag load.

Par 302 Page 9

(c) These high load events typically have detailed inspection instructions specified in Original Equipment Manufacturer (OEM) maintenance manuals. The objective of these instructions is to detect aircraft damage following an in-service flight or ground event. These instructions are typically referred to as Unscheduled Maintenance or Special Inspections. While there are many conditions that can result in high loads on the airframe and subsequent structural damage, the use of flight data in your inspection process is considered particularly beneficial for the events identified above.

(d) Your processes for evaluating these events should address 1) appropriate indication that an event has occurred, 2) evaluation of the severity of the event, and 3) coordination with the manufacturer, as appropriate. Your special inspection procedures for high load events should be robust enough to:

• Identify that a very high load event had occurred,

• Assure that indications of structural damage would be found in an initial inspection,

• Involve the OEM if necessary,

• Provide a process for additional inspections that would identify all of the structural damage, and

• Provide a process for approval for return to service.

(3) Technical Data that Describe Maintenance Standards, Methods, Techniques, and Procedures. This section of your manual concerns detailed procedures for accomplishing specific tasks. You should describe methods, techniques, technical standards, measurements, calibration standards, operational tests, structural repairs, and the like in this section. You should also include procedures for aircraft weight and balance, jacking, lifting, and shoring, storage, cold weather operations, towing, aircraft taxi, and aircraft cleaning. You can derive your maintenance manual contents from the manufacturer’s publications. However, based on your particular service experience, organization, and operating context, the FAA expects you to continuously modify and customize your maintenance manual as necessary for the continuing success of your maintenance program. This is one of the desired outcomes of a well-functioning CASS, which is explained in more detail in chapter 11 of this AC and in AC 120-79.

b. Work Cards. Work cards, while not a regulatory requirement, have evolved as a best practice. Work cards are considered part of your air carrier manual and the air carrier maintenance program. They are the “what to do” and the “how to do it” part of your airworthiness responsibility. Work cards are used as a simple means of complying with regulations for performing maintenance, as well as maintenance recordkeeping. Work cards provide detailed, concise procedural instructions that organize and control your maintenance activities while providing a means to ensure that your maintenance activities comply with your air carrier maintenance manual. It is an easy way to make sure maintenance, as well as other personnel are following your procedures. The second primary function is to document your maintenance activities, providing a means to comply with your air carrier maintenance

Page 10 Par 302 recordkeeping requirements. Work cards may also document the results of inspections, checks, and tests for data collection and analysis. Your work-in-progress audits of work card activity that you conduct under your CASS ensures that each person who accomplishes work on your aircraft is following your manual.

Par 400 Page 11 CHAPTER 4. AIR CARRIER MAINTENANCE ORGANIZATION

400. MAINTENANCE ORGANIZATION—GENERAL. You are required to have a maintenance organization that is able to perform, supervise, manage, and amend your program;

manage and guide your maintenance personnel; and provide the direction necessary to achieve your maintenance program objectives. You are required to include a chart or a description of your maintenance organization in your manual. You can read about maintenance organization requirements in part 121, subpart L, part 135, subpart J and portions of part 119, subpart C.

These organizational regulations apply to your organization, as well as any other organization that provides maintenance services for you. A chart is a good way to show your assignment of overall and direct authorities and responsibilities.

401. REQUIRED MAINTENANCE ORGANIZATION MANAGEMENT POSITIONS.

14 CFR § 119.65 includes specific requirements for maintenance management positions for operations under part 121. These are a Director of Maintenance (DOM) and a chief inspector, or equivalent positions. These are management positions required by the regulations; however, they are not all of the management positions that you will need to administer and manage your maintenance organization.

a. For operations conducted under part 121, § 119.65 requires you to have qualified individuals serving full-time in the DOM and chief inspector, or equivalent, positions. If necessary for your operation, you can ask the FAA for a deviation from the types and numbers of required part 121 or 135 management positions.

b. For operations that you conduct under part 135, § 119.69 requires you to have a qualified individual serving in the DOM management position; however, there is no regulatory requirement for a part 135 chief inspector management position. However, in a practical sense, you will have an individual in your part 135 maintenance organization who has direct responsibility for the RII function, as well as those other duties, responsibilities, and functions normally associated with a part 121 chief inspector.

c. In your manual, you are required to list the names and addresses, and to state the duties, responsibilities, and authority of each of your required management personnel. You should state in your manual who has overall authority and/or responsibility, and who has direct authority and/or responsibility for a given process. Also, you are required to notify the FAA when you make changes in your required management personnel or when you have a vacancy. In addition to these requirements for the part 119 required management personnel, you are also required to list the duties and responsibilities of all of your management personnel.

NOTE: Authority means the power to design or change fundamental policy or procedures without having to seek higher level approval. Authority is permission; it is a right coupled with an autonomous power to accomplish certain acts or order others to act. Often one person grants another authority to act, such as an employer to an employee, a corporation to its officers, or a governmental empowerment to perform certain functions.

Page 12 Par 401 NOTE: Responsibility means the obligation to ensure a task or function is successfully carried out. Responsibility includes accountability for the action to carry out a task or function.

402. REQUIRED AIR CARRIER MAINTENANCE ORGANIZATIONAL STRUCTURE.

a. The regulations defining an air carrier maintenance organization are necessarily broad given the different types and sizes of air carriers. A single means of compliance or a single organizational chart that would apply to all air carrier organizations is not possible.

b. You must designate a single person or position as the accountable manager with the authority and the overall responsibility for managing and implementing your entire maintenance program, including all inspection functions. The inspection functions and the required inspection functions are part of your maintenance program. The FAA expects you to designate your DOM as the accountable manager for your maintenance program.

c. The FAA expects your maintenance organization to have three general organizational functions to ensure all operations are conducted to the highest possible degree of safety. If you are a larger organization, you may have different departments for each level, while in the smallest organizations these functions may be carried out by one or two individuals. Generally, these three organizational functional levels include:

(1) Mechanics and/or inspectors performing the work at the first level (operations);

(2) Middle managers and supervisors at the second level (tactics); and

(3) The maintenance program accountable manager at the third level (strategy).

d. The FAA expects to see clear authority and responsibility in your maintenance organization, including delegated responsibility, for the overall maintenance program and all of its elements and functions. You should include a description of each individual’s duties and responsibilities in your manual so that there is not a fragmented organizational system with a high risk for confusion over who is responsible for a given element, process, or task.

403. ORGANIZATIONAL SEPARATION OF THE INSPECTION AND MAINTENANCE DEPARTMENTS.

a. There is a clear regulatory requirement for a maintenance organization at §§ 121.365 and 135.423. Because inspection is an integral part of your maintenance organization, there is no regulatory requirement for an inspection organization. There is no regulatory requirement to separate your inspection department, if you have one, from the rest of your maintenance organization, because inspection is integral to maintenance. The FAA has defined maintenance in § 1.1 as “inspection, overhaul, repair, preservation, and the replacement of parts, but excludes preventive maintenance.” If you choose to have an inspection department, you must organize it as an integral part of your maintenance organization.

b. Regulations require you to organize the performance of all maintenance functions, including inspection, repair, overhaul, and the replacement of parts, to separate the function of

Par 403 Page 13 required inspections from the function of the other maintenance, preventive maintenance, and alteration activities. This organizational separation must be below the level of administrative control where overall responsibility for the required inspection functions as well as the other maintenance, preventive maintenance, and alteration functions is exercised. Consistent with paragraph 402(b) of this AC, your DOM exercises overall authority and responsibility over the required inspection functions, as well as the other maintenance (including inspection), preventive maintenance, and alteration functions. See Figure 4-1 for a representative organizational chart

Page 14 Par 403 FIGURE 4-1. TYPICAL ORGANIZATIONAL CHART SHOWING THE

ORGANIZATIONAL SEPARATION OF THE RII FUNCTION AND THE OTHER

MAINTENANCE, PREVENTIVE MAINTENANCE, AND ALTERATION FUNCTION

OVERALL AUTHORITY

AND RESPONSIBILTY

FOR BOTH RII AND

OTHER MAINTENANCE

AND ALTERATION

FUNCTIONS

PART 119 DIRECTOR

OF MAINTENANCE

DIRECT RESPONSIBILITY

FOR OTHER

MAINTENANCE AND

ALTERATION

FUNCTIONS

MANAGER OF

MAINTENANCE

DIRECT RESPONSIBILITY

FOR RII FUNCTIONS

PART 119 CHIEF

INSPECTOR